1. Regulatory Information

1.1 Network Clearing LLC (US Money Services Business)

Full Legal Name: Network Clearing LLC
Common Name: Network Clearing
Entity Type: Money Services Business (MSB)
Jurisdiction: Montana, United States
Operating Address: 1001 S Main St Suite 600, Kalispell, MT 59901

Services: Money transmission, virtual USD accounts, digital asset custody and conversion, merchant acquiring, payment card services, foreign exchange, domestic and international funds transfer

Regulatory Framework: US federal (FinCEN) and state regulations
Target Market: Non-US residents

1.2 US Regulatory Registration

Network Clearing LLC is registered with the Financial Crimes Enforcement Network (FinCEN) as a Money Services Business operating in Montana and licensed or registered in states as required.

Federal Registration:

• Financial Crimes Enforcement Network (FinCEN): www.fincen.gov
• MSB Registration: 31000301293262

Important: Network Clearing LLC operates as a registered Money Services Business under US federal law. We comply with the Bank Secrecy Act (BSA), Anti-Money Laundering (AML) regulations, and all applicable state money transmission laws.

1.3 Partnership Services

Network Clearing LLC provides services directly and through partnerships with:

• Partner Financial Institutions for virtual USD accounts and banking services
• Regulated affiliates for specialized financial services
• Licensed payment processors for card issuing and acquiring

When services are provided through partners, you will be informed of the partner entity and your contractual relationship with that entity.

2. Risk Warnings

2.1 General Service Risks

WARNING: USE OF PAYMENT AND MONEY SERVICES INVOLVES RISK.

All payment and money services carry risk, including:

• Operational Risk: Service interruptions, delays, or errors
• Liquidity Risk: Delays in accessing funds or converting assets
• Counterparty Risk: Failure of partner institutions or payment networks
• Currency Risk: Exchange rate fluctuations
• Political and Regulatory Risk: Government actions may affect services

2.2 Digital Asset Risks

DIGITAL ASSETS ARE HIGHLY RISKY AND SPECULATIVE. YOU COULD LOSE YOUR ENTIRE INVESTMENT.

2.2.1 Extreme Volatility

• Digital Asset prices can fluctuate by 50% or more in a single day
• Prices may decline rapidly with no recovery
• Total loss of investment is possible

2.2.2 Lack of Regulation

• Digital Asset markets are largely unregulated
• Few consumer protections compared to traditional financial services
• Regulatory changes may negatively impact Digital Assets
• Governments may ban or severely restrict Digital Assets

2.2.3 Technology Risks

• Blockchain networks may fail or be attacked
• Smart contracts may contain bugs or vulnerabilities
• Digital Assets may become obsolete
• Quantum computing may threaten cryptographic security

2.2.4 Cybersecurity Risks

• Theft through hacking, phishing, or malware
• Loss of private keys means permanent loss of assets
• No recovery mechanism for stolen or lost Digital Assets

2.2.5 Irreversibility

• Blockchain transactions cannot be reversed or undone
• Mistakes (sending to wrong address) result in permanent loss
• No chargebacks or refunds

2.2.6 Lack of Recourse

• No deposit insurance (not FDIC insured)
• No consumer compensation schemes
• No government backstop or guarantee
• Limited legal recourse in disputes

2.2.7 Other Digital Asset Risks

• Market manipulation and fraud
• Lack of liquidity
• Fork and airdrop uncertainty
• Network congestion and high fees
• Delisting or loss of exchange support

YOU SHOULD ONLY USE DIGITAL ASSET SERVICES IF YOU:

• Fully understand the risks
• Can afford to lose your entire investment
• Have sufficient experience and knowledge
• Are comfortable with high volatility
• Do not need immediate liquidity

2.3 Foreign Exchange Risk

Transactions involving foreign currencies expose you to:

• Exchange rate fluctuations (which may be large and unpredictable)
• Currency devaluation or depreciation
• Foreign exchange controls or restrictions
• Costs of currency hedging

2.4 Custody Risks

FUNDS HELD IN CUSTODY ARE SUBJECT TO RISK:

• No Deposit Insurance: Your deposits and assets are not insured by FDIC or any government scheme
• Custodian Insolvency: Risk of loss if we or a partner institution becomes insolvent
• Theft or Loss: Risk of theft, hacking, or operational losses
• Regulatory Action: Authorities may freeze or seize assets

2.5 Operational and Technology Risks

Our Platform and services may experience:

• Downtime, outages, or interruptions
• Errors, bugs, or malfunctions
• Cybersecurity incidents
• Data loss or corruption
• Inability to access your account or execute transactions

We are not liable for losses resulting from operational or technology issues except in cases of gross negligence or willful misconduct.

2.6 Suitability

YOU ARE SOLELY RESPONSIBLE FOR DETERMINING WHETHER OUR SERVICES ARE SUITABLE FOR YOU. Consider:

• Your financial situation and objectives
• Your risk tolerance
• Your experience and knowledge
• Your time horizon and liquidity needs

If unsure, seek independent financial advice from a qualified professional.

3. No Financial Advice Disclaimer

3.1 No Advice

WE DO NOT PROVIDE INVESTMENT, FINANCIAL, LEGAL, OR TAX ADVICE. Our services are provided on an execution-only basis, meaning:

• We do not make recommendations
• We do not assess whether services are suitable for you
• We do not provide advice on financial planning or asset allocation
• Any information we provide is for general informational purposes only

3.2 No Reliance

DO NOT RELY ON ANY INFORMATION FROM US AS A BASIS FOR FINANCIAL DECISIONS. Information on our Platform, including:

• Market data and prices
• Charts and analysis
• Educational content
• News and commentary

Is provided for informational purposes only and should not be construed as advice or recommendations.

3.3 Independent Advice

If you need financial advice, you should consult an independent financial advisor who is qualified to provide advice based on your individual circumstances.

3.4 No Fiduciary Duty

We are not your financial advisor or fiduciary. We do not owe you any fiduciary duties except as expressly stated in our agreements or required by law. Our relationship with you is that of service provider and customer, not advisor and client.

4. Service Execution Standards

4.1 Best Execution Policy

We are committed to obtaining the best possible execution for your transactions, taking into account:

• Price
• Costs (commissions, fees, spreads)
• Speed of execution
• Likelihood of execution and settlement
• Size and nature of the transaction
• Market conditions

4.2 Execution Venues

We may execute transactions on or through:

• Partner Financial Institutions
• Payment networks (ACH, Wire, SWIFT, FedNow, RTP)
• Digital Asset exchanges and liquidity providers
• Foreign exchange markets
• Card networks (Visa, Mastercard)

4.3 Best Execution Report

You may request information about our execution quality by contacting support@networkclearing.us.

5. Fees and Charges

5.1 Fee Schedule

Our fees are set forth in our Fee Schedule, available at networkclearing.us or upon request.

5.2 Fee Changes

We may change fees at any time with 30 days' notice. Continued use of services after fee changes constitutes acceptance.

5.3 Currency Conversion

Foreign exchange transactions may involve spreads and markups. Exchange rates are determined at the time of transaction and may differ from interbank rates.

5.4 Third-Party Fees

You may be charged fees by third parties (such as partner institutions, blockchain networks, or payment networks). We are not responsible for third-party fees.

6. Complaints and Disputes

6.1 How to Complain

If you have a complaint, please contact us:

• Email: support@networkclearing.us
• Mail: Network Clearing LLC, 1001 S Main St Suite 600, Kalispell, MT 59901

6.2 Complaint Process

We will:

1. Acknowledge receipt within 5 business days
2. Investigate the complaint
3. Provide a written response within 30 days

6.3 Regulatory Complaints

If you are not satisfied with our response, you may contact:

• Montana Department of Administration, Banking and Financial Institutions Division
• Consumer Financial Protection Bureau (CFPB): www.consumerfinance.gov
• FinCEN: www.fincen.gov

6.4 Dispute Resolution

Disputes are subject to the dispute resolution provisions in our Terms and Conditions, including binding arbitration.

7. Privacy and Data Protection

7.1 Privacy Policy

Our collection, use, and sharing of your personal information is described in our Privacy Policy, available at networkclearing.us.

7.2 Data Security

We implement industry-standard security measures to protect your information. However, no system is completely secure, and we cannot guarantee absolute security.

7.3 Your Rights

You have rights to access, correct, and delete your personal information, subject to legal retention requirements. See our Privacy Policy for details.

8. Intellectual Property

8.1 Ownership

All content, trademarks, logos, and intellectual property on our Platform are owned by Network Clearing LLC or our licensors.

8.2 Limited License

We grant you a limited, non-exclusive, non-transferable license to access and use our Platform for personal, non-commercial purposes.

8.3 Restrictions

You may not:

• Copy, modify, or distribute our content
• Reverse engineer or decompile our software
• Use our trademarks without permission
• Frame or link to our Platform without authorization

9. Contact Information

Network Clearing LLC
1001 S Main St Suite 600
Kalispell, MT 59901

Customer Support:
Email: support@networkclearing.us
Hours: 24/7 (email); Phone: Business Hours (MST)

Compliance Inquiries:
Email: compliance@networkclearing.us

Privacy Requests:
Email: privacy@networkclearing.us

Legal Notices:
Email: legal@networkclearing.us

Last Updated: February 20, 2026
Version: 2.0

© 2026 Network Clearing LLC. All rights reserved.